California has the largest homeless population in the country — with more than 160,000 people estimated to be homeless — according to the United States Interagency Council on Homelessness. And in Sacramento, shelters are often full every night.

A landmark ruling by the 9th Circuit Court of Appeals in 2018 generally prevents cities from penalizing people sleeping outdoors or living in tents if adequate shelter is not available or offered.

California cities have struggled to manage homelessness since the ruling, with many local governments attempting to relocate camps under the ruling’s guidelines.

Sacramento cleared a highly visible camp Monday, and activists questioned the legality of the move, citing the Martin v. Boise decision.

The Bee looked at how other cities in California — including Modesto, Los Angeles and Chico — have cleaned up camps since the key ruling:

Modesto Refuge Efforts

In response to the growing number of homeless people setting up tents outside, Modesto officials decided to step up shelter efforts.

When Boise’s decision first went into effect in 2018, the city opened Beard Brook Park as a camp, then later closed it by opening an outdoor emergency shelter as it planned to create more shelter beds.

In 2019, the county ordered 600 additional shelter beds to include emergency shelter, supportive housing, and transitional housing throughout Stanislaus County to reduce the number of homeless people living in the streets and in camps, reported The Modesto Bee.

Venice Beach clears the camp

In the summer of 2021, Venice Beach officials decided to empty a homeless camp that had become a fixture on the city’s boardwalk. To do so, the city offered temporary and even permanent housing to about 200 homeless people displaced by the sweep, according to the Los Angeles Times.

“That’s why the program doesn’t end when there are no tents on the boardwalk,” LA City Councilman Mike Bonin wrote in a statement posted on his website in August. “The program ends when each person has secured permanent housing.”

Most of the people in the Venice Beach sweep were placed in temporary accommodations that included hotels and emergency shelters. In November 2021, the city of Los Angeles opened a village of 117 tiny houses, which provides a transitional housing option for homeless people in the area, Business Insider reported.

Outdoor shelter in Chico

In an effort to provide homeless people living on the streets with a place to stay, in June 2021, Chico attempted to turn parts of its municipal airport into a shelter, according to information from the Courthouse News Service. Authorities set up benches and gazebos for homeless people to spend the night in a secluded area of ​​the airport last summer.

The city had opened the tarmac to try to legally enforce its anti-camping ban and comply with the Boise ruling. This was in response to an ongoing lawsuit — Warren v. City of Chico — filed last April, according to a timeline from Chico Enterprise Record.

US District Judge Morrison England, however, ruled that the airport site did not count as sufficient shelter and could not be used as an available housing option to cite people living on the streets.

In a July 2021 decision that sided with eight homeless plaintiffs and granted a motion for a preliminary injunction against city ordinances, England wrote that the roofless asphalt tarmac “does not offer no real coverage or protection to anyone”.

In that case, the judge determined that, while the Boise decision does not provide a clear definition of shelter, it “appears to contemplate that the shelter will provide individuals with a place to sleep ‘inside.'”

The civil case continued until January and the lawsuit was settled.

Sacramento officials sweep the highly visible camp

Sacramento city officials cleared people’s belongings during a sweep of a homeless camp on Monday, displacing about 30 people who lived on the state-owned grassy lot.

The city had been trying to find housing for some of the people living in the camp over the past few months. While some residents were able to find temporary housing before the sweep, many were left homeless.

Sacramento recently leased the property to a group called Howe/Fair Oaks Property Owners Association. Leases aren’t mentioned in the Boise decision, so it’s unclear whether the sweep was legal.

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